The Turkish Data Protection Board announced the extension of VERBİS registration deadline until June 30, 2020.
December 2019
Record Retention is a Key Component of Your Privacy and Cyber Compliance Program
This blogpost summarises our recent webinar: “An urgent message from Berlin: The importance of record retention in privacy and cybersecurity”.
Schrems II: AG deems SCCs valid but comes up with difficult new obligations and expresses “doubts” over privacy shield
What has happened?
Yesterday, the Advocate General (“AG”) concluded that, in his opinion, the EU Standard Contractual Clauses (“SCCs”) are a valid mechanism to transfer personal data outside of the European Economic Area (“EEA”). However, the AG suggested new obligations for those using SCCs. They need to examine the national security laws of the country of the data importer to determine whether they can in fact comply with the terms of SCCs.
Russian Data Localization law: now with monetary penalties
On 2 December, a new law was introduced in Russia to enable substantial administrative fines to be imposed on organizations and individuals that fail to comply with data localization requirements. Both legal entities and responsible managers (e.g. the Data Protection Officer or the CEO) can be fined under the new regime.
Here We Go Again: Another Ballot Initiative for CCPA in 2020
As companies get ready for the California Consumer Privacy Act’s (CCPA) effective date of January 1, 2020, compliance is complicated because there are still several moving variables:
- Draft regulations have been proposed but may not be final until after January 1, 2020.
- The recent amendments to CCPA include two important exceptions (business-to-business (B2B) and the “employee” exceptions) that sunset on December 31, 2020. It is anticipated that amendments to CCPA will be introduced in the California legislature during the 2020 session on these topics and others.
- A ballot initiative to amend CCPA may be presented directly to California voters. The proposed initiative had originally been filed with the California Attorney General on September 25, 2019, but an amended ballot initiative was received by the Attorney General on November 13, 2019. This version has some potential surprises for companies subject to CCPA.